This question has been addressed in 1 Texas court opinion:
SCOTX — February 13, 2026
In Privilege Underwriters Reciprocal Exchange v. Mankoff, the Texas Supreme Court addressed whether a 'windstorm' deductible applied to damage caused by a tornado when the insurance policy left the term undefined. The homeowners argued the term was ambiguous because separate statutes and media outlets often distinguish between tornadoes and general windstorms. The Court applied the 'plain meaning' rule, determining that a tornado is fundamentally a 'subtype' of windstorm characterized by high-velocity winds. The Court held that the term was unambiguous as a matter of law and reversed the appellate court, ruling that extrinsic evidence or specialized statutory definitions cannot be used to create 'false ambiguity' in an otherwise clear contract.
Litigation Takeaway
“Draft with extreme precision: Texas courts will apply the broad 'plain meaning' of undefined terms in MSAs and decrees, regardless of whether a creative argument or external statute suggests a narrower interpretation. If you want a specific asset or expense excluded from a general category, you must explicitly define that distinction within the four corners of the document.”